New information (FAQ) on the Belgian UBO-register


We already informed you about the introduction and extension of the deadline of the register of Ultimate Beneficial Owners (UBO-register).


On 2 April 2019 the Federal Public Service Finance (FPSF) published an updated version of the document with frequently asked documents (FAQ). The updated FAQ clarifies, amongst others:

  • Who to register as UBO in case the shares of a Belgian company are held by a foundation, non-profit or trust;
  • In case of split ownership (bare ownership – usufruct) both persons need to be registered;
  • The matrimonial regime of spouses will impact who will qualify as UBO;
  • The persons who will qualify as higher management in case they have to be registered as an UBO;
  • What to do if your company has only a foreign legal representative.

Furthermore, some technical adjustments were made to the application on the UBO-register. You will, for example, no longer need to add documents on the origin of the shares of the legal entity.

In addition to the updated FAQ, the FPSF published a report of the OECD on the implementation of the UBO-register.


If you have any questions with regard to this matter, please reach out to your regular PwC advisor or contact Stefan De Plus (+32 3 259 30 08).